The One Big Beautiful Bill Act (OBBB) brings a pivotal change to Health Savings Account (HSA) eligibility and creates a new opportunity for employers to enhance the value of High Deductible Health Plans (HDHPs). Section 71038 removes a long-standing barrier that previously prevented employees enrolled in Direct Primary Care (DPC) from contributing to an HSA. This restriction limited employers’ ability to include DPC memberships in their benefits package—until now.
For those unfamiliar, Direct Primary Care (DPC) is a healthcare model gaining significant momentum, in which patients pay a monthly or annual fee directly to a primary care physician or practice in exchange for comprehensive primary care services. DPC removes insurance companies and third-party payers from the primary care equation, simplifying the process and often improving the quality of care.
The New HSA-DPC Rules Explained
Nate Goodman, owner of Goodman CPA and advisor to DPC practices, explains that the OBBB clarifies how DPC memberships fit into HSA-eligible plans by officially recognizing DPC fees as qualified medical expenses under the Internal Revenue Code. This means employees can use HSAs, HRAs, and other health accounts to pay for DPC memberships—without losing their HSA eligibility.
Effective January 1, 2026, the OBBB restores the Triple Tax Advantage for employees enrolled in both an HDHP and a DPC membership:
- Tax-deductible contributions: $4,300 for self-only and $8,550 for family coverage (2025 limits)
- Tax-free growth on invested HSA funds
- Tax-free withdrawals for qualified medical expenses—including DPC membership fees
Employers should be aware that services like labs and medications performed or sourced through the DPC clinic are subject to zero-dollar coverage rules and cannot be paid for by the employer outside of the HSA.
The IRS and Department of Health and Human Services are expected to issue further implementation guidelines. Still, employers have the remainder of 2025 to evaluate how to structure their health plan offerings for 2026.
Building a High-Value Health Plan: HDHP + DPC + HSA
When HDHPs were introduced, the goal was to encourage smarter healthcare consumerism. Unfortunately, the unintended consequence was that many employees delayed or avoided care due to high out-of-pocket costs.
With DPC now an allowable first-dollar care solution, employers can solve this access problem. The strategy is simple but effective: Pair a lower-cost HDHP with a DPC membership and allow employees to contribute to an HSA.
Designing a high-value health plan:
- HDHPs are less expensive than PPOs with comparable deductibles and out-of-pocket maximums. We confirmed a 10% savings with a major carrier. Those premium savings can be redirected to fund DPC memberships.
- DPC membership typically addresses 85% of care needs, including primary care, chronic condition management, and urgent concerns—with no copays or surprise bills.
- DPC services (outside of the membership), such as labs and minor procedures, are often a fraction of the cost through the DPC compared to the employer’s health plan. Our research at Kimmel Benefits+ has shown that DPC-sourced labs were, on average, 72% less expensive than the same services billed through insurance.
- HSA allows employees to save pre-tax dollars for other out-of-pocket costs like deductibles, coinsurance, and services outside the DPC membership.
As an advisor, I strongly caution employers against offering a standalone HDHP without a DPC option. Leaving employees to find and enroll in DPC on their own often results in low participation—and primary care is too important to leave to chance. Without engaged primary care, employers face downstream impacts, including escalated health issues and increased emergency room utilization. By including a DPC membership alongside an HDHP, employers secure better rates, simplify enrollment, and enable convenient payroll deductions, making it easy and attractive for employees to engage in essential primary care.
Why DPC Is Better Care
We’ve included DPC memberships in employer-sponsored plans for nearly a decade, and the feedback is consistent:
“I love my DPC.”
But what makes DPC so different? Dr. Chad Krisel, a long-time DPC physician and co-owner of Integrative Family Medicine of Asheville, breaks it down:
“In the traditional fee-for-service system, doctors are overwhelmed by packed schedules, insurance paperwork, and 10-15 minute visits. That model rewards volume—not relationships, not prevention, and not the kind of listening that real healing requires.
DPC flips that model. We don’t bill insurance, so we can keep patient panels smaller and visits longer. This gives us time to truly know our patients—not just their diagnoses, but their stories, goals, and barriers to health.
At Integrative Family Medicine, our DPC membership includes same- or next-day appointments, longer visits, virtual care, and direct messaging with our providers—all for a simple monthly fee. No copays. No surprise bills. Just a trusted relationship between patient and provider.
The result? Better access. Stronger relationships. Lower overall costs. And most importantly—healthier people. DPC allows us to practice medicine the way it was meant to be: personal, proactive, and deeply human.”
Employers now have a powerful opportunity to pair a lower-cost HDHP with a DPC membership and an HSA—creating a plan that delivers better care, stronger employee engagement, and long-term cost control. If you’re planning your 2026 benefits, now’s the time to explore how this model could work for your team. Contact Kimmel Benefits+ to learn more.